Grants

Let's examine some of the ethical issues surrounding grants. May you represent the non-Federal entity back to the Government on a grant application? Not surprisingly, the answer is: maybe.

As in other representational activities, if you want to be involved in this, then your scope of work MUST include writing grant applications. If it doesn't, you can't participate in this activity without violating the criminal prohibition.

Note, however, that even if such assistance is included in the scope of work, the EPA Office of General Counsel nevertheless advises that such assistance be provided "behind the scenes" and that your name, title and position are not included on the application. If it's essential to do so, then OGC advises that you identify yourself as an EPA employee on an IPA assignment.

But, you still have another ethics concern! The EPA's competition policy prohibits EPA employees from helping outside organizations to write a grant application package for a grant that will be awarded by the EPA. Furthermore, you're going to have another ethics issue (misuse of position) if you contact your EPA colleagues to try and get a favorable decision for the non-Federal organization on a grant application that it has pending before EPA. Not only that, but you may well be precluded under the impartiality rules from working on that grant when you return to federal service.

The Bottom Line: If there's a possibility that you might participate in any grant application work with your host organization, you might find it prudent to discuss it with an EPA ethics official.